March 7, 2019 VIA ECF The Honorable Nicholas G. Garaufis United States District Judge United States District Court 225 Cadman Plaza East Brooklyn, New York 11201 Re: United States v. Keith Raniere, 18 Cr. 204 (NGG) Dear Judge Garaufis:

We write in response to the government’s letter notifying the Court of what it asserts is a “potential conflict” with Teny Geragos’ representation of Keith Raniere and Mark Geragos’

 

representation of Clare Bronfman because they are “closely related.” (Dkt. 390 at 1.)

 Counsel has made clear to both Raniere and the government that she is aware and takes seriously her ethical duties to her client

 — 

including the duties of confidentiality and loyalty. These duties have not and

will not be impaired by her “close family relationship.” (

Id. at 2.) We do not believe there is a conflict; however, if the Court would like to conduct a Curcio hearing, we have provided Curcio counsel, Avraham C. Moskowitz, with t

he government’s letter 

 and are able to proceed with a hearing on the next court date, March 18, 2019. Respectfully submitted, /s/ Marc Agnifilo Teny Geragos cc: All Counsel (via ECF)

Case 1:18-cr-00204-NGG-VMS Document 403 Filed 03/07/19 Page 1 of 1 PageID #: 3883